ML19260C426

Second Set of Interrogatories.Requests Further Info Re Intervenor Contentions Re NRC 790507 Order,Facility Personnel Competence & Adequacy of Emergency Instructions. Certificate of Svc Encl

ML19260C426
Person / Time
Site:	Rancho Seco
Issue date:	12/17/1979
From:	Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	CALIFORNIA, STATE OF
Shared Package
ML19260C420	List: ML19260C421 ML19260C425 ML19260C426
References
NUDOCS 7912260345
Download: ML19260C426 (7)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)\\

SACRAMENTO MUNICIPAL UTILITY

)

Docket No. 50-312 (SP)

DISTRICT

)

)

(Rancho Seco Nuclear Generating

)

Station)

)

SECOND SET OF NRC STAFF INTERROGATORIES TO THE CALIFORNIA ENERGY COMMISSION CEC)_

Pursuant to 10 CFR 9 2.740b, the following interrogatories are directed to CEC.

Each interrogatory, unless objected to, is to be answered separately and fully in writing, under oath or affinnation, by individuals having personal knowledge of the answers.

Pursuant to the agreement of the parties and the Licensing Board's " Order Relative to Proposed New Schedule" of December 4,1979, final discovery requests are to be served by December 17, 1979 and final responses to discovery are to be served by January 17, 1980.

Pursuant to 9 2.740(e), these interrogatories should be supplemented as required by the above-referenced rule.

Interrogatory 10 A.

Does CEC contend that the short-term modifications and actions required by subparagraphs (a) through (e) at page 4 of the Commission's Order of May 7, 1979, are inadequate? If so, specifically describe the inadequacies.

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8.

If the answer to Interrogatory A above identifies any inadequacies, provide the reasons supporting CEC's claim of inadequacies.

Interrogatory 11 A.

Does CEC contend that the long-tem modifications and actions required by the Conmission's Order of May 7,1979 in this proceeding (p. 5) are inadequate? If so, specifically describe the inadequacies.

B.

If the answer to Interrogatory A above identifies any inadequacies, provide the reasons supporting CEC's claim of inadequacies.

Interrogatory 12 A.

Does CEC contend that Rancho Seco personnel inadequately understand the mechanics of the facility, basic reactor physics, or other fundamental aspects of the operation of the Rancho Seco Facility? If so, specifically describe the inadequacies.

B.

If the answer to Interrogatory A above identifies any inadequacies, provide the reasons supporting CEC's claim of inadequacies.

Interrogatory 13 A.

Does CEC contend that Rancho Seco personnel are not adequately apprised of new information pertinent to the facility's safe operation and/or ability to respond to transients, particularly information on operating experience of other reactors? If so, specifically describe the inadequacies.

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, B.

If the answer to Interrogatory A above identifies any inadequacies, provide the reasons supporting CEC's claim of inadequacies.

Interrogatory 14 A.

Does CEC contend that emergency instructions are inadequately under-stood by or not adequately available to plant personnel in a manner that allows quick and effective implementation during an emergency? If so, specifically describe the inadequacies.

B.

If the answer to Interrogatory A above identifies any inadequacies, provide the reasons supporting CEC's claim of inadequacies.

Interroaatory 15 A.

Does CEC contend that systems identified as contributing to releases of radioactivity during the TMI accident, which are outside of containment, should be changed to vent into the containment building? If so, specifically identify those systems and the reasons for your position.

Interroaatory 16 A.

Does CEC contend that the containment building should be modified to provide over-pressurization protection with a controlled filtered venting system to mitigate unavoidable releases of radionuclides.

B.

If the answer to Interrogatory A above is in the affirmative, provide your reasons.

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. Interroaatory 17 A.

Does CEC contend that the special features and instruments installed at Rancho Seco are inadequate to aid in diagnosis and control after an off-normal condition engendered by a loss-of-feedwater transient? If so, specifically describe the special features and instruments.

B.

If the answer to Interrogatory A above is in the affimative, provide your reasons.

The following infomation is sought with respect to the " California Energy Commission's Resxnses to First Set of NRC Staff Interrogatories" filed on December 5,1979 (Answers).

Interrogatory 18 With regard to CEC's Answers, specifically its Response to Interrogatory 3, identify and describe all "... indications that personnel at TMI-2 did not have such information..." and "... indications that personnel at other oper-ating reactors may not have such information."

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Interrogatory 19 Hith regard to CEC's Response to Interrogatory 6, identify and describe "Other possible event scenarios related to feedwater transients [which]

could cause overpressurization leading to a breach of containment".

Respectfully submitted, MK/

Richard K. Hoefling Counsel for NRC Staff Dated at Bethesda, Maryland this 17th day of December,1979.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

SACRAMENTO MUNICIPAL UTILITY Docket No. 50-312 DISTRICT

)

)

(Rancho Seco Nuclear Generating

)

Station)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "SECOND SET OF NRC STAFF INTERR0GATORIES TO FRIENDS OF THE EARTH (F0E)" and "SECOND SET OF NRC STAFF INTERR0GATORIES TO GARY HURSH AND RICHARD CASTR0" and "NRC STAFF REQUEST TO PRODUCE DIRECTED TO GARY HURSH AND RICHARD CASTR0" and "SECOND SET OF NRC STAFF INTERR0GATORIES TO THE CALIFORNIA ENERGY COMMISSION (CEC)", in the above-captioned proceeding, have been served on the following, by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 17th day of December, 1979:

• Elizabeth S. Bowers, Esq., Chairman Gary Hursh, Esq.

U.S. Nuclear Regulatory Commission 520 Cr.qtoi rcli

^

Washington, D. C.

20555 Suite 700 Sacranento, California 95814

• Dr. Richard F. Cole Atomic Safety and Licensing Board Panel Mr. Richard D. Castro U.S. Nuclear Regulatory Comissico 2231.( Street Washington, D. C.

20555 Sacre.nento, California 95816

• Mr. Frederick J. Shon Jamel S. Reed, Esq.

Atomic Safety and Licensing Board Panel Michael H. Remy, Esq.

U.S. Nuclear Regulatory Commission Reed, Samuel & Remy Washington, D. C.

20555 717 ( Street, Suite 405 Sacramento, California 95814 David S. Kaplan, Esq.

General Counsel Chr'stopher Ellise1, Esq.

Sacramento Municipal Utility District Dian Grueneich, Esq.

P. O. Box 15830 Calt fornia Energy Commission Sacramento, California 95813 lilt Howe Avenue Sac amento, California' 95825 Thoinas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D. C.

20036 1618 309

. Herbert H. Brown, Esq.

Lawrence Coe Lanpher, Esq.

Hill, Christopher and Phillips, P.C.

1900 M Street, N.W.

Washington, D.C.

20036 Mr. Michael R. Eaton Energy Issues Coordinator Sierra Club Legislative Office 1107 9 Street, Room 1020 Sacramento, California 95814 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.

20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comission Washington, D.C.

20555 aK/d Richard K. Hoefling Counsel for NRC Staff i

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